Japan Inheritance Guide for UAE (アラブ首長国連邦) Nationals
This guide explains how Japanese inheritance law and tax apply to UAE nationals living in or inheriting property from Japan. There are approximately approx. 1,000 UAE nationals residing in Japan.
1. Applicable Law (準拠法)
Under Japan's Act on General Rules for Application of Laws (法の適用に関する通則法, Article 36), the inheritance of a person is governed by the national law of the decedent.
UAE Federal Law No. 28 of 2005 (Personal Status Law) governs succession for Muslims based on Islamic law. For non-Muslims, the DIFC Wills Service Centre (Dubai) or Abu Dhabi's non-Muslim personal status law (2023) may apply. The UAE applies the nationality principle.
Renvoi (反致): Generally Does Not Apply
The UAE applies Islamic law mandatorily to Muslim nationals' succession and does not recognize renvoi. For non-Muslims, recent reforms allow choice of home country law, but this does not constitute renvoi in the traditional sense.
2. Tax Obligation Type (課税範囲)
Unlimited Taxpayer
Taxed on all worldwide assets.
Applies if: domiciled in Japan, OR foreign national with residence visa who has lived in Japan for 10+ years.
Limited Taxpayer
Taxed only on assets in Japan.
Applies if: not domiciled in Japan, OR foreign national who has lived in Japan for less than 10 years.
Japan has a tax treaty with UAE that may provide relief from double taxation.
3. UAE Inheritance Law
- •Mandatory Islamic inheritance shares (faraid) for Muslims, following primarily Maliki and Hanbali jurisprudence
- •Recent reforms (2023): non-Muslims can now apply their home country's law to succession in certain emirates
- •Testamentary disposition for Muslims limited to 1/3 and cannot benefit a Quranic heir
- •The UAE does not impose inheritance tax
Statutory Inheritance:
For Muslims: Sharia shares apply. Wife receives 1/8 (with children) or 1/4 (without). Sons receive double daughters' shares. For non-Muslims: home country law may apply under recent reforms.
4. Required Documents
Inheritance Certificate from UAE Court
UAE Sharia court or personal status court certificate listing heirs and shares.
Emirates ID / Passport
UAE national identification or passport.
Consular Authentication
The UAE is NOT a Hague Apostille Convention member. Documents require authentication through the UAE Embassy and MOFA.
Certified Japanese Translation
All Arabic/English documents translated into Japanese.
5. Professional Fees
| Professional | Fee Range |
|---|---|
| Tax Accountant (税理士) | ¥300,000–¥800,000 |
| Lawyer (弁護士) | ¥500,000–¥1,000,000 |
| Judicial Scrivener (司法書士) | ¥80,000–¥200,000 |
| Translation & Authentication | ¥80,000–¥200,000 |
6. Important Notes
- ⚠The UAE does not impose inheritance tax; only Japanese inheritance tax applies
- ⚠The Japan-UAE tax treaty provides income tax relief
- ⚠The UAE is NOT a Hague Apostille Convention member; consular legalization is required
- ⚠Recent UAE reforms (2023) allow non-Muslims to apply their home country's law, significantly changing the landscape
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Frequently Asked Questions
Does the UAE have inheritance tax?
No. The UAE does not impose inheritance or estate tax. Only Japanese inheritance tax applies to Japan-located assets.
Does Islamic law apply to all UAE nationals?
Islamic inheritance law applies mandatorily to Muslim UAE nationals. Since 2023 reforms, non-Muslim residents and nationals in certain emirates can choose to apply their home country's succession law instead.
Can UAE documents be Apostilled?
No. The UAE is not a member of the Hague Apostille Convention. Documents require authentication through the UAE Ministry of Foreign Affairs and the Japanese Embassy in the UAE, or the UAE Embassy in Japan.
UAE Guides by City
Guides for Other Nationalities
This tool provides rough estimates only. It does not constitute tax advice or tax filing services. Actual tax obligations may differ significantly. Please consult a licensed tax professional (税理士) for accurate calculations.